A strategy for clean air or is it still hazy?
By Graham Harker, Senior Associate - Air Quality
The Government has produced a draft Air Quality Strategy for consultation, although it is difficult to understand what is actually going to be done. A strategy is usually defined as ‘a plan of action designed to achieve a long-term or overall aim’; so you would expect the Air Quality Strategy to contain lots of actions. Unfortunately, the actions are more like a collection of aims, without a lot of detail about how these aims are going to be realised. For those of us involved in development, it makes it difficult to provide a logical response or to understand the implications.
On the plus side, the first couple of chapters on ‘Understanding the problem’ and ‘Protecting the nation’s health’ provide a good overall summary of the issues that the strategy is designed to address. For anyone wanting an understanding of what the main issues are with respect to pollutant emissions, and what their effects on human health and the environment are, it’s well worth reading.
Then, things get a little hazy. The Air Quality Strategy sets lots of targets for the reduction of emissions, with some large percentage reductions quoted. At first sight this appears ambitious and laudable. However, the targets are set against a baseline of 2005, with targets for reductions to be achieved by 2020 and 2030 respectively. Given that the final strategy is to be issued in March 2019, most of the initial pollutant reductions to 2020 will have already been achieved by dint of previous policies and action. This is confirmed in Section 10 of the document, where apart from PM2.5 and ammonia, it is confirmed that the emission reductions will be achieved by 2020. It gets more difficult by 2030, where it states that further action will be needed to meet the non-methane volatile organic carbon targets. Looking at the data presented, the same could be said for PM2.5 and ammonia emissions. The strategy therefore doesn’t seem to deliver on the targets set for reductions in emissions.
In terms of public health, the most eye-catching element of the strategy is the goal to reduce PM2.5 levels in order to halve the number people living in locations where concentrations of particulate matter are above 10 µg/m3 by 2025. If this can be achieved, it will be a major benefit in terms of human health and is to be welcomed as an aim. The way of achieving this aim is by ‘a comprehensive set of new powers designed to enable targeted local action in areas with an air pollution problem.’ This doesn’t really explain the ‘how’, instead, it points to local authorities being made responsible for doing something, which if past history is anything to go by, won’t be very successful.
For developments, the most concrete proposal is to ‘provide guidance later in the year for local authorities explaining how cumulative impacts of nitrogen deposition on natural habitats should be mitigated and assessed through the planning system.’ We will need to see what this says, but our understanding is that the Government disagrees with Wealden Council’s approach to the assessment of cumulative impacts of traffic on the Ashdown Forest and therefore this should help clarify what needs to be done and should help to free up development around European designated sites.
The other interesting nugget of the strategy is something that again is promised for later in the year: a strategy to deal with road transport emissions termed ‘Road to Zero’. This promises an approach to addressing exhaust emissions from road transport. As the emission standards for the vehicles themselves are set at a European level, this can only mean that the Road to Zero strategy will set out how the Government intends to facilitate the change to electric vehicles.
As for what should be included, I would suggest:
- An end to energy policy that requires building large energy centres in cities which directly impacts upon local air quality.
- A commitment to ensuring all buses have emissions equivalent to Euro VI or better by 2025.
- A commitment to fully integrated transport systems in every major city with single ticketing across all modes of public transport.
Overall, therefore, there are not a lot of concrete proposals in the Clean Air Strategy. It does contain a lot of public awareness and information providing activities which haven’t been very successful in the past at leading to reductions in emissions. Perhaps the success of the strategy lies in further increasing the public’s desire for action on air quality, leading to the changes in behaviour and acceptance of concrete action that will actually achieve clean air.